Limitation bars reassessment where Section 148A(d) order and Section 148 notice are issued beyond the prescribed period.

Reassessment proceedings under the Income-tax Act cannot be sustained when the Section 148A(d) order and consequential Section 148 notice are issued beyond the prescribed limitation period. The Gujarat High Court applied its earlier ruling on the same legal position and treated limitation as determinative, with the result that the impugned order and notice were quashed as time-barred. The petition succeeded, and the reassessment proceedings did not survive.

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Issues: Whether the order under Section 148A(d) of the Income-tax Act, 1961 and the consequential notice under Section 148 of the Income-tax Act, 1961 were liable to be quashed on the ground of limitation.

Analysis: The challenge concerned reassessment proceedings for the relevant assessment year. The impugned order and notice were tested against the limitation issue, and the Court followed its earlier decision on the same legal position to hold that the proceedings could not be sustained beyond the prescribed time limit.

Conclusion: The impugned order under Section 148A(d) and the consequential notice under Section 148 were quashed as barred by limitation.

Final Conclusion: The petition succeeded and the reassessment proceedings did not survive.

Ratio Decidendi: Reassessment proceedings and the consequential notice cannot be sustained when they are initiated beyond the period of limitation prescribed by law.

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